Rick and Ruth Baime Richards - Page 23

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          located, and what she was to wear.  She would also note whether             
          she had a callback and whether she was hired.  According to the             
          diary, during 1994 Mrs. Richards had one modeling shoot with                
          United States Purchasing Corp. (for their catalog) and four                 
               Since the acting jobs were sporadic, Mrs. Richards worked as           
          a clerk, registrar, and secretary for the Palm Springs Unified              
          School District (PSUSD).  Mrs. Richards worked for PSUSD for 29             
          years and had retired before the year at issue.  During 1994,               
          Mrs. Richards received income from her pension, from the College            
          of the Desert (a book store where she worked part time), and from           
          serving as a proctor in administering the Scholastic Aptitude               
          Test.  Mrs. Richards received as compensation $1,574 for the                
          modeling shoot with United States Purchasing Corp.                          
               On their 1994 Schedule C, petitioners claimed the following            
          expenses with respect to Mrs. Richards’ actress-model activity:             
                  Expense                                 Amount                      
               Academy players directory (listing)          $60                       
               Agent fees                                   262                       
               Photo session                                267                       
               Duplicate photo                              231                       
               Must-see shows, plays & movies               480                       
               Miscellaneous                                960                       
               Long distance telephone calls                270                       
               Cash telephone calls                       56                          
               Total                                      2,586                       
               As before, we initially must decide whether Mrs. Richards’             
          actress-model activity was engaged in for profit.  Upon reviewing           
          the entire record, we conclude that during 1994, Mrs. Richards              

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